Case 1 :04-cv-00138-JJ F Document 63-2 Filed 05/O3/2005 Page 2 of 2
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. _ ` April 4, 2005
By Facsimde
Rodger D. Smith, Esq.
Morris, Nichols, Arsht & Tunnel
1201 North Market Street
P.O. Box 1347
Wilmington, DE 19899-1347 ,
Re: GIECH Carp. v. Scierntfc Games International, Inc., etal.
Q. De!. CA. No. 04·138-JQ)
Dear Rodger:
We have your March 31, 2005 letter. It is our understanding that we have received all of
the Pollard litigation documents and have produced those to you, with the exception of those
containing confidential information of parties not within our control which are covered by the
protective order entered inthat case. If we locate anything further, we will let you know.
As for the document subpoenas of Messrs. Turek, Fulton and Burr, you already have Mr.
Turek’s documents. They were produced with hates numbers GTECH 36095-38158 on March
23, 2005. Mr. Fulton has no responsive documents except the videotape of his deposition in the
Pollard litigation which we are reviewing. As for Mr. Burr, as you know per his March 31, 2005
email to you, he is in the process of gathering relevant, responsive documents. We will process
and produce those to you shortly after we receive them.
Sincerely,
Larissa A. Soceoli
i
p New York Washington. BC Sulcon Valley wwvmxenyomcem
TUTRL P. G2
Case 1:04-cv-00138-JJF
Document 63-2
Filed 05/03/2005
Page 1 of 2
Case 1:04-cv-00138-JJF
Document 63-2
Filed 05/03/2005
Page 2 of 2
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